Who counts as a SMF6? Identifying the 'other key decision makers' at your club
Five of the IFR's six Senior Management Functions map relatively neatly onto recognised roles: Chair, Chief Executive, Chief Finance, Chief Operations and Director. The sixth does not. SMF6 -- Other Key Decision Maker -- is a catch-all for people outside SMF1 to SMF5 who exercise sustained, high-level authority or influence over a club's regulated activities. The IFR's final May 2026 ODSE Guidance now gives clubs a non-exhaustive set of in-scope and out-of-scope examples. This article uses that final guidance to examine sporting directors, technical directors, recruitment personnel, legal counsel, medical staff and other borderline roles.
The legal test: the Act, the ODSE Rules and the final Guidance
Section 4(4) of the Football Governance Act 2025 says that a person is a senior manager where, in relation to the club's activities, they carry out a senior management function specified by the IFR. Section 4(5) supplies the statutory boundary: the function must involve responsibility for managing one or more aspects of the club's affairs where the way those aspects are managed could have serious consequences for the club. Managing includes taking, or participating in taking, decisions about how those affairs should be carried on.
The specific SMF6 definition is in rule 5.1(f) of the IFR's ODSE Rules: it is the function of having a significant influence on the management or conduct of one or more aspects of a regulated club's affairs in relation to its regulated activities. Paragraphs 2.15 to 2.18 of the final ODSE Guidance explain that this means a continued and high degree of decision-making authority or influence over the day-to-day management and conduct of those regulated activities, in a role not already covered by SMF1 to SMF5. Rule 5.2 specifies these functions for permanent appointees; temporary cover is governed separately.
Job title is not decisive. But nor is any decision with serious consequences enough on its own: the role must satisfy the Act and the specific SMF6 test, including the connection to the club's regulated activities.
The IFR's confirmed examples: what the final Guidance tells us
The final May 2026 ODSE Guidance contains an express, non-exhaustive table of roles and responsibilities the IFR would and would not expect to fall within SMF6. The in-scope side includes: a Sporting Director with a high degree of executive decision-making authority over matters affecting financial soundness, such as transfers or contracts; people outside the board with executive authority over matters affecting financial soundness, including major expenditure; and other executive or non-executive roles outside SMF1 to SMF5 with decision-making authority over matters affecting financial soundness or heritage.
The out-of-scope side is equally important. It includes a Sporting Director with minimal or no executive authority whose responsibilities are purely sporting and on-pitch; first-team managers and coaches without authority over transfers or other financial matters; medical staff and scouting personnel who are likely to lack authority over transfers, contracts or financial matters; and facilities or operational staff without overall responsibility or decision-making authority for the club's regulated activities. These are expectations, not irrebuttable classifications: the Guidance says the table is indicative rather than exhaustive and the facts of each role remain decisive.
What the final IFR Guidance does -- and does not -- settle
The May 2026 ODSE Guidance gives clubs an official, non-exhaustive table of roles and responsibilities the IFR expects to be in or out of SMF6. Medical staff, scouting personnel, first-team coaches and sporting directors without executive transfer or contractual authority now have a clear published starting point.
The table is still indicative. A role not named in it may be caught, and two people with the same title may be treated differently. Clubs must assess the actual function, including whether the person has a continued and high degree of authority or influence over the day-to-day management and conduct of regulated activities, and whether another SMF is the correct category.
Sporting directors and technical directors: the clearest official contrast
Sporting Director is the clearest role-specific contrast in the final Guidance. A Sporting Director with a high degree of executive authority over transfers, player contracts or other matters affecting the club's financial soundness is an expected SMF6. A Sporting Director with minimal or no executive authority, focused purely on sporting and on-pitch activities and unable to authorise transfers or contracts, is an expected non-SMF6.
Technical Director remains a fact-sensitive title because clubs use it differently. Where the role is effectively a Sporting Director position with sustained, high-level authority or influence over transfer strategy, contracts, material expenditure or another regulated activity, SMF6 may apply. Where it is a specialist sporting role focused on playing style, coaching methodology or academy pathways, without the relevant executive authority or influence, it is closer to the out-of-scope sporting roles in the IFR's table. Requiring final board approval is relevant, but it is not automatically conclusive: the Guidance refers to both authority and influence, and the Act includes participating in decisions.
Heads of recruitment: the Guidance now gives a clearer starting point
The final Guidance places scouting personnel among the sporting roles the IFR would generally expect not to be in scope, because they are likely to influence player identification without holding executive authority over transfers, contracts or financial matters. That is the best starting point for an ordinary Head of Recruitment role. The conclusion can change where the actual remit goes materially further -- for example, a continued and high degree of authority or influence over which transfers proceed, contractual commitments or expenditure affecting financial soundness. The question is not simply whether another person signs the contract, but who in substance holds sustained influence or authority over the regulated decision.
Legal counsel: the professional-advice carve-out is narrower than it first appears
Section 4(3) of the Act contains a professional-advice protection, but its scope must be stated precisely. It prevents a person from becoming an officer under section 4(2)(b) merely because another officer is accustomed to act on advice that person gives in a professional capacity. It does not create a blanket exemption from the separate senior-manager route in sections 4(1)(a) and 4(4) to 4(6), or from the SMF6 definition in the ODSE Rules.
Ordinary legal advice to a board or executive should not, by itself, make a lawyer an SMF6. The position becomes different if the General Counsel's actual role extends beyond professional advice and gives them continued, high-level authority or influence over the management or conduct of regulated activities. A formal board directorship or shadow-director role should be considered under SMF5, rather than treated as SMF6 merely because the person is a lawyer. Delegated signing authority, committee membership, veto rights and the way decisions are actually made are therefore relevant evidence, but none is a standalone test.
Club doctors and heads of medical: the final Guidance gives a clear starting point
The original statutory language can make medical roles look like an open question because clinical decisions can have serious sporting, safety, legal and reputational consequences. The IFR's final Guidance resolves the ordinary case more directly. Its out-of-scope examples expressly include medical staff and other sporting roles: although they may influence asset condition through player fitness, the IFR says they are likely to lack executive authority over transfer decisions, contractual agreements or other financial matters.
A club doctor or Head of Medical should therefore not be mapped into SMF6 merely because their clinical judgement is important or has serious consequences. An exceptional role could still require separate analysis if it also carries a continued and high degree of authority or influence over the club's regulated activities and is not covered by another SMF. That would be an unusual extension of the role, not the ordinary result for independent clinical decision-making.
Other roles worth a club's own consideration
The same framework applies to other borderline roles. Clubs should test the actual duties against the SMF6 definition, ask whether the authority or influence is continued and high-level, identify the relevant regulated activity, and check first whether the function properly belongs within SMF1 to SMF5.
Head of Academy or Head of Youth Development. A normal sporting, coaching or player-development remit is unlikely to be enough. A materially wider executive remit over major academy expenditure, commercial commitments, strategic change or heritage-related decisions may require a different analysis, particularly where the individual exercises sustained authority or influence over those matters.
Head of Commercial or Head of Partnerships. A job title containing 'Director' does not itself create SMF5 status: the final Guidance says a Commercial Director is not automatically a Director function unless they actually serve in the relevant board or company-law capacity. A senior commercial role may nevertheless be SMF6 where it carries continued, high-level authority or influence over material commercial decisions affecting financial soundness or heritage.
Data Protection Officer or Head of Compliance. Independent advice, monitoring or escalation responsibilities do not automatically amount to SMF6. The question remains whether the person's actual function gives them a continued and high degree of authority or influence over the day-to-day management and conduct of the club's regulated activities. A broader executive compliance remit may be caught; a specialist advisory or statutory oversight role may not be.
For the full detail of all six Senior Management Functions, the approval process and the personal consequences of an ODSE determination, see Lagom's existing guides to the ODSE regime and personal enforcement.
The title is not decisive. The sustained authority or influence the role carries over regulated activities is what matters.
Lagom Sports Compliance is the leading specialist governance, risk, compliance and anti-financial crime consultancy built exclusively for professional football, globally. We support club leadership teams with evidence-based SMF mapping. We work through the organisation chart, delegated authorities, committee structures, reporting lines and the way decisions are made in practice, then test each role against the Act, the final ODSE Rules and the IFR's current Guidance. If your club has a Sporting Director, Head of Recruitment, General Counsel, Head of Medical or another role whose title does not settle the answer, get in touch and we will help you build a defensible mapping before an appointment or IFR query creates urgency.
For licensing, we offer:
Review Only support for clubs preparing their own application who want an independent, criterion-by-criterion review before submission;
Part Support for clubs that want to lead certain work-streams while we own others; and
Full Support, where a named senior consultant leads the entire licensing project from readiness assessment through to post-submission.
For ODSE specifically, we help CEOs and their leadership teams map exactly who in the organisation is in scope, assess individual readiness against the fitness and source of wealth tests, and build the material change notification process that keeps you compliant for as long as you hold the role, not just at the point of your original determination. If any of the concerns above sound genuinely familiar, get in touch and we will talk through what the right level of support looks like for your specific position.
We have also built a self service IFR readiness assessment tool. It takes around 15 minutes to complete and gives you a guide as to what you may need to, based on what you already have in place.
Frequently asked questions: SMF6 and other key decision makers
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SMF6, Other Key Decision Maker, is the function of having significant influence on the management or conduct of one or more aspects of a regulated club's affairs in relation to its regulated activities. The final IFR Guidance says it covers people outside SMF1 to SMF5 who have a continued and high degree of decision-making authority or influence over the day-to-day management and conduct of those activities. The actual responsibilities matter more than the job title.
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No. The final Guidance expects a Sporting Director with a high degree of executive authority over matters affecting financial soundness, such as transfers or contracts, to be in scope. It expects a Sporting Director with minimal or no executive authority and a purely sporting or on-pitch remit, unable to authorise transfers or contracts, to be outside SMF6.
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Yes, but it is non-exhaustive. Table 1 of the May 2026 ODSE Guidance gives both in-scope and out-of-scope examples. It includes sporting directors with high executive authority and other roles with authority over financial soundness or heritage on the in-scope side; and sporting directors without that authority, coaches, medical staff, scouting personnel and certain facilities or operational staff on the out-of-scope side. A role missing from the table is not automatically outside SMF6.
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Not by itself. Section 4(3) prevents professional advice alone from making a person an officer through the 'accustomed to act' route in section 4(2)(b). It is not a blanket exclusion from SMF6. A lawyer whose wider function carries continued, high-level authority or influence over regulated activities may still require analysis, while a lawyer who is a formal or shadow director should be considered under SMF5.
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The IFR's final Guidance gives a clear ordinary-case answer: medical staff are among the sporting roles it would expect not to be in scope because they are likely to lack executive authority over transfers, contracts or financial matters. An unusually broad executive role could still require assessment, but clinical importance or serious consequences alone do not make a club doctor an SMF6.